Honorable John LaFalce
2310 Rayburn Building
Washington, D.C.  20515-3229                             September 30, 1996

Dear Congressman LaFalce:

     As you know, the federal Department of Energy (DOE) recently
announced a final cleanup plan for the Tonawanda, NY FUSRAP(Formerly 
Utilized Sites Remedial Action Program) Site.  The process used by 
DOE to arrive at this plan has both broken apromise made to the 
Tonawanda community and raised serious legal issues involving potential 
violation the prescribed environmental impact statement (EIS) public 
review process (see FACTS' September 28 letter to Mr. James Owendoff, 
DOE, enclosed).  

       Since release of the EIS review documents and the cleanup
plan alternatives by DOE in 1993, the Tonawanda community has
evidenced overwhelming support for Alternative #2, i.e. the
complete removal of the 371,000 cubic yards of radioactive wastes
identified by DOE in those documents to a suitable off-site long-
term storage location.  As a DOE-recognized community stakeholder
group representing health, environmental, and resident interests in
the Tonawanda community, we have actively supported this cleanup
plan.

     As you may know, Congress established the FUSRAP (Formerly
Utilized Sites Remedial Action Program) in 1974 for the intended
purpose of cleaning up properties contaminated by nuclear weapons
production operations of the Manhattan Project and Atomic Energy
Commission to a level of residual contamination that would enable
DOE "to certify the sites for unrestricted use following
decontamination, to the extent possible." (page 3, "Remedial
Actions at Four FUSRAP Sites in New York: Notice of Intent to
Prepare an Environmental Impact Statement", February 22, 1988, DOE) 
It is possible to fully decontaminate the Tonawanda Site for
unrestricted use (seeEIS Alternative #2).

     As used in the phrase "to certify for unrestricted use", the
term "unrestricted use" has a specific meaning: that pattern of
human use which results in the greatest radiation dose to the site
user, generally accepted to be a "resident farmer" use scenario. It
does not include patterns of limited use, for example industrial
use scenarios or open space use scenarios, where major limitations
on both the time and the possible pathways of radiation exposure
are assumed.  In this context such uses are restricted uses.
Alternative #2 is the only alternative that will fully discharge
DOE's congressionally-mandated responsibility under the FUSRAP.

     Considering the indefinite duration of the radioactive hazard
(500,000 years), the expectation of continued high population
density in the Tonawanda area for the foreseeable future and
corresponding pressures to more intensively re-use the properties,
the likely inability or unwillingness (or even absence) of future
governments to place or to maintain restrictions on the use of the
contaminated private properties, and the availability of much
better physical sites where the long-term isolation of the wastes
is both better assured and more cost-effective, we believe
adherence to this goal of cleanup for unrestricted use is essential
if we are to adequately protect many future generations of site
users from radiation-induced death and injury.  Our position on
this issue has evolved as our understanding of the factors involved
in making such a determination has grown, as we have reflected on
the historical record of events to date, and as we have accepted
our collective societal responsibility as the generators (and their
sons and daughters) of these radioactive toxins.

     Determination of federal spending priorities is a very
important part of your job as a federal representative of the
interests of your constituents in the Tonawanda community.  The
Alternative #2 cleanup could be accomplished for approximately $200
million -- half the cost of a single space shuttle flight.  The
coalition of community interests we represent thinks that the
proper management of nuclear waste should be given a higher
priority than the space program.  Therefore, we request that you
make every effort to secure a transfer of this amount of existing
spending from the space program in order to fund a thorough cleanup
of the Tonawanda Site.

                                   Sincerely,



                                   James Rauch


Enclosure

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